LEGAL

Digital Currency Balances

Coinbase secures customer digital currency through a combination of secure, online servers and offline (“cold”) storage. Coinbase maintains 98% or more of customer digital currency in cold storage, with the remainder in secure online servers as necessary to serve the liquidity needs of our customers.

Coinbase maintains commercial criminal insurance in an aggregate amount that is greater than the value of digital currency we maintain in online storage. Our insurance policy is made available through a combination of third-party insurance underwriters and Coinbase, who is a co-insurer under the policy.

The policy insures against theft of digital currency that results from a security breach or hack, employee theft, or fraudulent transfer.

Our policy does not cover any losses resulting from unauthorized access to your personal Coinbase or GDAX account(s). It is your responsibility to use a strong password and maintain control of all login credentials you use to access Coinbase and GDAX. Digital currency is not legal tender and is not backed by the government. Digital currency, such as Bitcoin, Litecoin, and Ethereum, is not subject to Federal Deposit Insurance Corporation (“FDIC”) or Securities Investor Protection Corporation protections.

Cash Balances

Cash balances, such as U.S. Dollars, British Pounds, Euros, customers store with Coinbase are held as a balance in your Coinbase or GDAX account(s). For U.S. customers, Coinbase combines your balance with the balances of other customers and holds those funds in custodial accounts at U.S. banks and/or invests those funds in liquid U.S. Treasuries in accordance with state money transmitter laws. For non-U.S. customers, funds are held as cash in dedicated custodial accounts. All custodial pooled amounts are held separate from Coinbase funds, and Coinbase will neither use these funds for its operating expenses or any other corporate purposes.

To the extent U.S. customer funds are held as cash, they are maintained in pooled custodial accounts at one or more banks insured by the FDIC. Our custodial accounts have been established in a manner to make available pass-through FDIC insurance up to the per-depositor coverage limit then in place (currently $250,000 per individual). FDIC pass-through insurance protects funds held on behalf of a Coinbase customer against the risk of loss should any FDIC-insured bank(s) where we maintain custodial accounts fail. FDIC insurance coverage is contingent upon Coinbase maintaining accurate records and on determinations of the FDIC as receiver at the time of a receivership of a bank holding a custodial account.